Waste Crime in the UK: Tackling Illegal Dumping, Enforcement Gaps and the Cost to Communities

(upbeat music) - Welcome to the EFW podcast. I'm Dr. Stephen Wise. I'm one of your regular hosts. And today I'm delighted to welcome to join me at Gareth Rollings and Dr. Anna Willits. So Gareth and Anna, I will let you do a little introduction about yourselves, please, 'cause you can do it far better than I can. So Gareth, first up, please. - Hi, yeah, Stephen. So my name is Gareth Rollings. I am the head of waste at West Texas County Council. But aside from that, I am the chair of Lara, which is the local advisory committee, which I started in January this year. Hopefully for four years, but a two year stint. So I represent all the views of our members. We've got around 80% now of local authorities across some Scotland, Wales, England, and Northern Ireland at the moment. So I represent quite a wide range of different councils, local authorities and council's in all waste meters. - And Anna. - Morning, Stephen. And thank you all for inviting me to be on the podcast. Gareth and I have a, is our second double act, isn't it, Gareth? I'm having an energy free waste conference in March. But today we're in our houses. So the introduction I'm a partner at Gunnacook, which is a law firm. I'm a criminal environmental defense lawyer. And I act for regulated industry within the waste sector. So businesses that deal with waste resource management, large businesses, SMEs, and individual directors and individuals who are dealt with through the regulatory regime. I act for landowners. I act for businesses. I act for tenants. The whole gamut. So as I say, I will clarify, I regulate industry. People often say, oh, waste crime. Oh, you act for all the waste criminals. How do you do that? And I would stress, there's a very, there's a very different and a very large range of environmental crime and the real, the sharp end of it is not my remit. As I say, I act for regulated industry and landowners. Really, thank you very much. And today we're going to be talking about waste crime. And we're going to cover both that regulated side and the impact around, you know, our communities as well, which, you know, Gareth, you'll have a lot of experience around that. And as Anna said, we've actually sat on a panel together. We, I chaired the panel on waste crime with both of you back in March at the energy from waste conference. And I'm hoping we can sort of talk about some of the changes we've seen since then. There's been a number of announcements by government into terms of how they might regulate this. But also, and rather alarmingly, we've seen the discovery of yet a few more large waste crime sites as well. And I think not just that, there's been a lot more in the press to do with local authorities and sort of waste crime on the streets. If I can say that, the sort of the smaller end, the very visible when you're out and about in the community. And so hopefully we can pick up some of these as we talk through it. So from a general perspective, we talked about it back in March. What would you say has been the biggest positive changes that you've seen since March in terms of waste crime? Anna, if I could come to you first, please. Thank you, Stephen. I would say I always try to be just awful about these things. And waste crime really drives me up the wall. And there's very frustrating for my regulatory clients when the likes of Hodewood and Kiddlington are going on. But always try to be positive. And things do feel like they're changing for me. We've had a lot of frustrations in regulatory for a number of years, feeling nothing's been done. And I think thanks to the House of Laws Inquiry last September and the press coverage of this since then, it's really illuminated this aspect of waste crime. The public are very interested in it. I'm very pleased to see BBC, Channel 4, Sky News. All of the main broadcasters have been highly interested in this. And it's really pushed us to forefront. And I think as a result, that's also pushing some change within government and the regulator. They can't ignore it anymore. They could have ignored it for a few years when Anna talked about it. But when the press and the House of Laws are pushing it, I think that's really been helpful. So it slightly feels like things are moving and changing. We've had some initiatives coming out from the government at 10 point planned. I have to say, a little bit less overwhelmed by those than I thought they could have been. They could always go further. And I think there's a lot of things they could have done if they're actually spoken to industry. But that's maybe for later. But yes, I would like to be positive and say that it feels things are moving. I mean, it's sad to say, as you've said, Steve, and discovery of more illegal waste sites that are there. So that's not such a good thing. But again, the fact that the press are jumping on the street on the BBC, as soon as they hear it, maybe that's going to keep the pressure up and keep them positive to try and effect some change. And I think as you said there, Anna, as well, it has stayed within the public sort of consciousness as well. This isn't something that's just been a sort of a, it's been around for a couple of months. And then everybody's forgotten about it. It's very much stayed there with new sites being discovered. You say the regulation is starting to be looked at and new initiatives. But it doesn't seem to have disappeared, which I think is a really good thing. It's staying there and there's that focus on it. And Gareth, from your perspective, in the local authority side of things, what changes have you seen since March sort of had that sort of positive, you know, positive changes to reflect that have happened? So I think Anna's right. I think the fact that it's managed to stay in the in the news and relevant is obviously really, really, really positive thing. Disappointing last week to see the announcement of new sites, particularly when there was quite a big one and something like a hundred thousand tons. - Oh, it's an island, yep. - Well, there was one near me in Horsham. And it's commercial and industrial, but that site's sat in West Sussex. - Yeah. - Certainly I didn't have a clue. And my council didn't have a clue about it, but because commercial and industrial, we sort of weren't involved. But that list, I just worry that this is going to get longer and longer and longer and longer and longer. And without actually anything in terms of it, actually being created away, because as we know, the cost of the expense of doing this is far exceeds budgets in local authorities. So I think the fact that it has sort of come to a bit of a head, I think we're talking about it. So that's good. I know that the COWN now have got some work that they're looking at doing on that as well. And then there's potentially some other work happening with the end of a meeting soon with myself, Anna and Margaret Bates, working on it. So I think a lot of us are trying to sort of get involved in that arena and carry on talking about it at the same time. I think my biggest fear, I should actually might come on to that in a little bit later on, but my biggest fear is that this list just continues to grow exponentially year on year. And actually the actions that get taken or come from this don't actually end up reducing it or stopping it. So it's a difficult one, but I think the fact that we are all discussing it, we're still talking about it, it's still on the news, it's still been investigated and particularly that the fact that it was being discussed at Parliament and stuff like that of the House of Lords. But I don't know if you picked up that one of the amendments that got made in the House of Lords was that they wanted to make all local forages once more for clear away material. - In this, yeah. - And I'm out of where it come from. So myself, free Lara, can I know that Nordeaux and Dept and all the other parties all wrote quite strongly back to the minister to say that's not acceptable. We cannot do that, so that didn't go through. But that's, to me, that's quite scary because that would just below every financial situation that the Council's face out of the water. - Yeah, so if you've had, you know, you're talking about the site within your own county, a hundred thousand tonne in a super site in terms of illegal commercial industrial waste being deposited there, that is gonna cost tens of millions to remove and remediate and you say, you've got no budget for that. It's something that if that was thrown at you to go, well, it's in your county, you've got to do it. That's like, how does that happen? When you don't have a budget sitting around to just handle illegal waste sites, you know, it's critical money. - Yeah, and I think some of those, some of the sites, some of the size of these sites, you know, I deal with around, I deal with a lot of tonnages. I think it's about 300,000 tons in total a year, so obviously it made up of lots of different things, but in terms of like my domestic, what we call black bag waste, it's around 150, 160,000 tons a year. So the size of some of these big sites, that's three years worth of all of my residents, black bag waste, you know, three years from every resident. Well, it's 900,000 residents almost, so you're talking a crazy amount. So when you start looking at those numbers, you do start seeing the scale of how just difficult it is to sort of like get that moved away and how quickly, you know, it takes me, you'll take me three years to move that waste on an everyday basis. - That's just huge, isn't it? And, you know, from a local authority perspective, you said covering England, Scotland, Wales and Northern Ireland, where does, where does sort of, and perhaps people don't know this, but where does sort of your level of responsibility is a local authority and in terms of waste crime, having to deal with that, you know, local fly tipping, is there sort of a size that you have, then you also have somebody else, or? - Normally, if it's at anything over a large, lorry loaded, it should 40 environment agency, and we would pick up anything that's under a smaller size. I mean, some of the things we are seeing now, certainly I've seen it more locally down here, is things like caravans being abandoned full of waste, I've seen Arctic trailers being abandoned full of waste, and they still fall sort of inside the scope of what a local authority would deal with, and that has sort of a double whammy because you've got to get the vehicle emptied before it can be taken away, but you have no idea what's inside that vehicle. So from then a legislative perspective, you then need to almost test or take the material out and treat it as hazardous, but anything smaller and sort of a large, tipper load would likely fall to the local authority. Anything that's over that sort of size moves over to, it should move over to the environment agency. I'm not convinced how much they deal with that on a local basis, but there we go. - And I was gonna just ask you about that, where Garrett has sort of suggested there's that transition from the local authority having to be responsible and deal with it, get them passes to the environment agency. How proactive are they when they're asked to go out? get involved with something? Have we seen a positive change over the last few months or is it still very much business as usual? All right, my personal experience is I haven't and I have clients who regularly report waste crime at a garage right. There's a memorandum of understanding the government that less than a typo load is, like authority, usually about 20 tonnes more than that is the garment agency. One house had lost issues and I think they were told by Mary Crane, I don't know why, she said it, that it's always very confusing. Nobody knows who to report what to the law, cross what, no, it's not confusing. That is the memorandum of understanding your own government, that is what it should be. The trouble we then find on the ground, in which we raise with the House of Laws, is the slightly slippery shoulders of the department's not wanting to deal with it and I found myself when my clients have reported large scale waste crime to the environment agency, they're often told all notes to local authority and we had to go back, say no, it isn't, it's you, this is clearly more than 20 tonnes but they don't seem to want to deal with it. I've then had another environment agency regulator department say to my client that it's the different, but it's the local authority under building regulations and we've had to say no, it isn't. We went to the local authority to start with and they said it's the environment agency, the environment says no, it isn't. So you go around in circles, I haven't seen that improving and that was something we raised with the House of Laws last September, I don't understand why this happens and why does the, these cropped, blurred lines that aren't even there and the police and crime commission for Kent who sat with me in a gay evidence from his perspective at the House of Laws said he finds the same thing, it seems to go all around the houses and reporting that people don't want to deal with it and they can understand why it likes to go around 700,000 tonnes. It's a big thing to do with that but it's actually your job and what you do with it and just picking up a point and you said Gareth about and you being told to force you, it's not happened but it's suggested that local authority pay, it's not, it's not a local authority paying, is it? It's the taxpayer paying and that's what's frustrating, it's what we're being asked to clear up these messes and my personal view is that maybe instead of government coming out with these jikens ideas, maybe think about prevention in the first place so we don't get to these stages, focus your efforts on trying to tackle the problem rather than pick who's picking up the, they are there, many to be dealt with already but what's more important to me is prevention, roles and cure, so you aren't in that situation, Gareth, where you and your tax dollars have been asked to put the bill for it. And I guess there's two things as well if I can deal with both of you on them in terms of the prevention is better than cure, there's going to be one thing driving the large-scale waste sites and there's going to be a reasons for that and then Gareth at a community level, at a local level, other things are going to be driving it, perhaps sort of similar underlying issues or tensions are being caused, so for example, household waste recycling centres being closed because there isn't the budget to maintain them and so you then get people going, yeah I'm not traveling across towns to go to my nearest site, I'm just going to go dump it around the corner or if you've got people doing their clearance, they don't check whether the people coming in to do that clearance, you know, have all the relevant permits or licenses and are properly authorized to do it and I suppose so you face at that end and it must be really frustrating. Yeah I think there's quite a number of things that are unpacked because the difficulty is here is that so if you go to the fact that as a resident, if I do the right thing and do my check on, I've found out this person, they've said they're registered waste carrier, I think the honest answer is that I've think I'm still recently so I'm registered dead dog as a waste carrier, I think the cost of doing it is very cheap, so you can do that, here you go I'm registered waste carrier, but when someone turns up and says to you, I can take that waste around for away for £30, £40, £50, you know, he's doing that not just at one resident they're doing it at a number, you know that could be two, three, four, five, six hundred pound in the back pocket per day, but because waste is expensive to dispose of, you have no choice but to pay to get rid of it and I think the unscrupulous people that are carrying out that sort of, let's class that as a low level fly tipping, you know, low level fly tipping is not happening by local residents, you know, they're not residents who have gone to a site and been rejected, they're not residents that are frustrated, they it's likely a commercial entity who's doing it, certain navigate in the law and there's get and because they can get away with it and you know one of the main reasons they're getting away of it is because the the enforcement of this but for local authorities is a massive resource strain, you know, if you're talking about having to get involved with legal solicitors, legal people serving notices, having trained officers to deal with it, these issues don't always actually sit within the waste team either, so the waste team of the people who picked this material up, but actually it might sit in environmental health or somewhere else that actually is supposed to enforce against it, they don't have the flim pact of, well, you know, I don't need to worry about doing anything on it because I'm not, I haven't got the pressure on my budget to deal with it, so when you sort of look at the stats of low level fly tipping that's happening, I think a lot of it, we think that most of that is commercial, so you know, we do a lot of work at our sites to stop commercial people coming in, but the honest answer is you can't let commercial people come and dispose their waste for free, every, let's think about this this morning, it's like every item we buy, there is a cost to dispose of it, no matter what it is, if you buy a glass, a cup, a packet of crisps you pay, certain amount of money to get the buy that product, but actually you'll not think, you know, your dispose element is, well, just put it in my bin, I don't worry about it sort of thing, and I think that goes for everything doesn't it, so even if you go down the lines of I'm going to paint my house, you know, you're going to paint your house great, but you're going to make waste, you're going to make yep, paint tins, you know, there's no producer pays responsibility on that side of things, it's just chuck it in your bin or take it to a recidenter and someone else pays for it, so when you've got work being done at your home, or if, you know, you've got a lot of stuff outside, skips are expensive, if you don't live on a street where you can put a skips, so you have to get a skip license or you haven't got a garden sort of thing, hippo bags, I mean, hippo bags are relatively good value, but they're quite small, I know a number of local authorities down here do a, you can buy a grab bag now through the local authority, which is, which tends to be cheaper, and I think all these things just work towards the fact that why people choose that actually, you know, well, I'll just pay that person, it's out of sight, out of mind, I've given that person, probably cash, and he has gone, and the likelihood of it being found out, but I guess for you, what, what you're seeing with your, your customers is that that material's being tipped in the same place, and suddenly that small fly tip becomes a giant and a big fly tip, doesn't it? That's what we're seeing. Yeah, some of the landowners I have for it, we'll start off with a man in a van, and then they get wind of, oh, there's no cameras here, or there's six entrances, you can come and do with that, and then, and very quick to this kind of waste, particularly RDF as well, I know, I know that's not from households, but it can build it very, very quickly, and then my clients and the landowners are served notices to clear it up, and then, oh, then believe it or not, fund sales prosecuted for knowingly committing, you can't see me doing the real, realise listeners can't see me doing a verticommer's sarcasticly, but knowingly committing illegal depositive waste on their lands, by which time, of course, the fly by night has done it a long gone. I guess as you said there as well, I know that is the thing, it's ultimately it's the landowner, your client, that gets prosecuted, and has to bear the cost of clearing up that site, whereas you say they may not have known anything about it, they might try and stop it, or they're going to go, I'm not, I can't just stop it like that, because I'm going to be, you know, put my safety at risk, yet, yet they're the ones that ultimately are found to be having to be responsible for it all, which is a bit ludicrous. Yeah, I'll try not to, well, last year very saying, beg to the regulator to help them clear this guy off, when he first took over the tendency, absolutely fine, then he turned quite nasty, baseball bats, nobody wants, you know, asked the regulator to help, they refused to help, they said nothing, that's your problem, he set fire to vehicles, he mentioned the mark on his prosecuted for knowingly committing this happening, and that's the way the law is structured, that it is an offense, but yeah, it's very frustrating. With some of these big sites, and you mentioned things like RDF being tipped illegally on land, that's somebody who has got an operation, which takes in either household or commercial waste, has put it through a process, it could be shredding, screening, whatever it may be, and they've produced a refuse to arrive fuel, so they've knowingly done that, and then sent it somewhere, so these, some of these are people that know the regulations, and know exactly what's going on, and yet are choosing purposefully to obviously do an illegal activity, that makes it even worse, because if so many companies want trying to do the right thing within the sector, and then you've got these that are in the sector, and doing it knowingly, that's really frustrating. Yeah, they're often referred to sort of a different sector, I think three sectors to waste crime is regulated industry, who occasionally things go wrong and assign more blow down or drive a car in a second, etc, then there's the real OCGs, the organised crime gangs, in the middle, there's the operators who appear to be legitimate, again I'm doing my inverted commas, operating in plain sight, often will have permits, and are sort of in the middle organising all this, and you often find, I've asked you for clients at the moment, who are unwittingly pulled into this, by operators appearing transportation, wholly as appearing to be legitimate on the face of it, my clients are now absolutely everything they should, as the way to produce it, their waste has gone to site A, they've got actually some of them actually gone to the site, looked at it, checked it, met director, checked the permit, gone more than need to, check the permits on the public register, checked the codes, match up, checked the delivery of the vehicles, the vehicles turn up, take the waste away, unbeknown to them, somebody else is in the vehicles, take it to site B, then my clients prosecute as a producer for their waste being, they had no idea it had gone to that site at all, and they're told they haven't done enough in their duty of care to make sure it's gone to site A, well I would argue, and I am arguing, we're going to call for you to that, sort of following the lorry, sort of following the lorry up there in one, absolutely, what would it be? We would do away with the whole waste to haulage business, we can't be doing that, how do you know when you've done all of those checks and absolutely everything, but then some joker has gotten disrupted to the chain, so, and again, this brings me into one of the points I think you touched on Gareth about waste producers and Kidlington, I understand, is some low authority waste, and schools waste has been found, I'm pretty sure the low authorities in schools haven't deliberately said oh let's send out waste to an illegal site, I'm pretty sure they've everything they should have done as far as they can. And then that's when the chain then can get murky and things can change in the middle. So again, I've sympathy with waste producers on that, where the waste has, they've done everything they should have done it, it hasn't jumped somewhere it shouldn't. And we can't legislate for everything in that. And I also, I know a lot of you said, DRS is going to solve this client's narrative, it's dubious about this, but maybe it's a story of the different podcasts. And I guess from, you know, probably the, I think you've both mentioned it, one of the biggest fundamental underlying causes is the cost of waste disposal. So, you know, quite rightly, we're making it more expensive to dispose of waste because we want, we want it done in a way that is safe, protects the environment, protects human health. And some of that cost must, therefore the cost goes up, or we don't want certain materials going into landfill. And then there are, you know, very good reasons for that. And we're introducing things, obviously things like the emissions trading scheme coming into the EFW sector. But again, it pushes the cost up even further. So it will, you know, may well have an unintended consequence of increasing more of this crime. How, how do we sort of balance that up with this ever increasing cost? And then, you know, is there a correlation really between this cost increase and the amount of waste crime that's gone on? Is there something clear there? Or is that, is that just an easier assumption to make? I think it's a bit of both. I mean, waste, I mean, I've been in the waste entry 20-odd years now, and the cost has just gone up and up and up. I mean, if you take, was it last year, the landfill tax went up by, you know, increased by a crazy amount, you know, for West Sussex County Council, where I work, you know, we put very little waste to landfill, but even that small increase, I think it's a cost of 200,000. And it was like, well, we can't do anything else with this waste. We'd already come off the back of the pollute, pollute, you know, pops coming through that costus extra money. And there is, you know, whether we like it or not, there is no cheap way of getting rid of material, you know, particularly when you start getting into some of the like more difficult waste streams, you know, to think thinking things like hazardous waste and stuff like that. So you can't, you know, it's just so difficult to actually try and bring the cost down. And when the cost has finally come down, I'd say, say, say AFG energy for waste market brought cost down for a period or, you know, the increase in recycling, suddenly you've then got an emissions trading scheme coming in which sort of takes down into it. And I think, you know, when it was being, I mean, I managed close landfill sites in my team and putting waste in the ground isn't the answer, you know, instead of generations to come. But I just, you know, I've been thinking about this heavily around how do you deal with keeping cost down? But even I sort of used the word quite a lot cost avoidance because for all that, you know, if you would get the cost reduced by a few pound a ton, that's great if your tonage is going down as well. But if the tonage is going up and up and up and up, it doesn't really help you yet. So I'm not overly sure if there is a room to produce a pay principle works, you know, the idea is that the person who's producing the material has to cover the cost of it. But we've just seen, you know, we've had the EPR come in for packaging, you know, that's put like one that's put a cost on producers of about 1.6 million pound. That's not even covering, you know, the commercial industrials size of waste is gulfs. Yeah. The domestic size. That's sorry, the domestic size isn't gulfed by it. So, you know, when you try and look at how much money is involved in that and I'm sure Annie will agree and you're pretty talking it. But, you know, these, these people are so organised, they can, they can buy a piece of land, they can get in and get out, tip all this waste, they've made an absolute fortune. And yeah, they've gone and they can't, you know, just on the back of what's happened so far, we haven't seen that many arrests get made or that many, that much more information in the public than made about what's actually happened. Hannah, do you want to come in on that in terms of how this is happening on that commercial scale? Yeah. Yeah, absolutely. Grega, Gareth, the criminals are very clever. That's why gosh, they put their efforts into some useful. But yeah, they are very, they're running rings around the regulation that they always have done. And again, that's my skepticism about DRS, they know exactly how to get around that. And the land buying is interesting, we've seen that recently with them convoluting and clouding, sorry, muddy and water, as I was meant to say, about how land is broken up into parcels, purchase, so then it makes more difficult to see who actually owns the land, who's responsible. And that's been to something we've seen not a number of the illegal sites. And that's all been planned and dealt with an event. So again, very clever mechanisms of dealing with it. And then, you know, arresting people for months after you found it. And then letting them go once you arrested them. I mean, you can just hear the synthesis. And my voice about how that's been dealt with, you need to be a step ahead of them. And there are always a step, the moment, always a step ahead of the regulators. So the 10-point action plan of all, we're going to use more drones, well, great. It's the way to deal with this. Yeah, it's been like after the event, yeah. Yeah, I guess you know, just saying, for example, they might arrest somebody, but there's obviously been financial transactions going on. And the problem with the key bit is where's that money gone? Where's the money trail? Because you might arrest somebody, but they might not directly have the money from it. It's gone somewhere. So how are they picking up the money trail to go? Well, actually, we've got to freeze those accounts because we need that money to help back to sort of recover that waste. Well, it did make me wonder when Mary Crowe said after Kidlington, we're going to make the people who did this pay. And I thought, that's interesting. I wonder how you're going to do that. Because polluter pay's principle is there. But that works once you can find the polluter catch them, arrest them with grounds to keep them in custody. So they don't disappear off the Cayman Islands and sit there with a cocktail, laughing at us all, keep them in custody. And then how are you going to make them clear up the site and pay for it, stand over them whilst the illegal waste operator then properly and methodically clears up a site, testing it to check it's got as it's wasted or not, how are they going, how are she going to do that? And then nine and a half millions of clear Kidlington, do I think these people have got nine million pounds sitting in their bank account, hand over and go, yes, I'll pay to clear that up. So it's not quite as straightforward as to say, yes, we're going to make them pay for it. And following the money and freezing the bank accounts, it's a little bit late when it's all up and isn't it? Because it's like the polluter pay's works very well for, I'll call it businesses that are doing things compiliently and legally and they'll do it. They will do that. It doesn't work. It's quite right, as you say, when it's involved in illegal activities that that money disappeared somewhere. People are patches and it's all very muddy. It doesn't work. It needs to be treated by something far more serious. You don't, you know, how we don't go very much like the polluter pays for cigarettes or vapes or something in the same way at the moment. So it doesn't necessarily, how do we, what do you think needs to be done to sort of bring them to just this for one of a better word? How do we address this? Well, I have some views on this. Man, I'm sure the regulation might have different views. But doing things earlier rather than waiting till after so Kidlington, my frustration with this is this was known about in June, last year early June. Businesses, regulations you've been reporting made multiple reports of this site to regulate, as with Hodeswood, nothing was done until the 23rd of October when a restriction order was applied for. So four months, this site has sat there polluting the environment getting worse and worse and worse, and more waste has been tipped there and nothing was done. Now that could have been stopped quickly months ago. And the sooner you do things, the more able you are to gather intelligence on vehicles, who's driving them, who's doing what. So my view is, getting into these sites more quickly, we're stopping, for example, the site of Wigan, I understand environment agency office to tell the local MP Josh Simon's that they couldn't close down a site because there's a criminal investigation ongoing. Sorry, that's not true. So, and I think about a year went by with nothing happening and it could have done enough on that really angous me because we all want the best environment. We're all in this industry because we want that. And for the regulator to say that, and so we can't just record that when you can. And again, as soon as you get into these sites, the way intelligence gathering works is it's a lot more easy to do and you're like, and the same with Postwood, similar, and they were sent photographs and videos of Laurie's in and out with registration plates on the same over in Austria. Nothing was done. And it catching people and doing things sooner and more importantly, the harms the environment, ceasing it and mitigating it at the earliest stage. Get on and do the action. You can as many drones as you like. There's many DRS systems if you like. If the officers don't get out and do something, that's what I think needs to be happened. That's might be, what do you think the reticence is? I have a wonder about this, Stephen, when I'm, I go running a lot and often think about these sorts of big questions when I'm running him. And I was thinking about it yesterday. I think there's a number of factors. Again, I don't work for the regulator. I'm sure that you will get a different view. But I'm as soon as a number of factors, some of these sites, the OCGs, we know who runs them, well, maybe don't have intimate knowledge of them. But I know from our clients that some of these sites, there will be pretty unpleasant, savory characters, which I'm not sure. I'm not sure. I'm not sure. I'm not sure. I'm not sure. I'm not sure. I'm not sure. So I imagine there's an element of that. But then for me, that's what the NCA and the police are there for. To deal with those, that kind of, if you're not suitable to do that, that, that, so I can see there might be reticence there. I'm also confused. I have to say about the use of restriction orders and closing sites down. That power has been available since 2018 after all, Pinkton. The waste of fuel. And it's only been used six times in 2018, 2026. Let's restart. Not very much. No, and then I raised this with the House of Lords. And I also said it to anybody that would listen to chamafor and the BBC in last October in November about, I don't understand why this power is there. It's a really harsh power. It has to be, when an application is made, it has to go by the magistrate's call in 72 hours. And it's there for serious pollution. So I said a number of times, I don't understand. There must be a reason why the regulator is not doing this that I don't know about. And then between November and March, May, now, I think we might, in March, when I looked, it'd been used 12 times in four months. So I don't understand whether the regulator didn't know it didn't have that power, or whether it did know and didn't want to use, not just those options are very attractive. And I don't know which it is, but I'll be positive, no, they aren't having more use. So I don't, I don't know, I don't see a question seeing the reticence in dealing with these things. Why is the regulator? Yeah, it's like a regulator. And Gareth's point earlier, there's a big site, 100,000. Yeah, maybe it's just think, oh, this is too big. Oh no, we'll go to Anna's client. They've got a skip in the wrong place. We'll go around there. They won't have balaclabs, and we'll have a cup of tea, and we'll have a drink. things. So again a big cynical and you might get different answer but that's how myself and I know my clients feel about it. Well I do wonder with with the you know the reaction speed and stuff what would happen tomorrow if an Arctic Lorry went down a town's you know a pretty big town centre say Arandel town centre which is a historic town centre and three or four Lorry's turned up in in that on that road and just suddenly started tipping the way stale. I wonder how many would tip before I got stopped. Yep. And who would stop them because I suspect the police would go this local authority issue. The local authority went pretty much probably when I've a response to be able to deal with it. All they're going to do is send out some officer who's just going to be able to go you can't do that. Well I'm doing it and then when EA get involved and finally turn up and you know it sounds stupid but I do actually query actually what would actually happen in that situation. And I don't know what I reckon would happen. I reckon it would be the public who would stop it. Yep they get fed up with it and I reckon it would be the public and the shop owners who would all get together and do something. I mean I think it would be the local authorities or the people that have powers to do it. I mean from a police perspective the police would go but it's not we can't do anything would they? They might arrest them or they know they might be trying to stop them but I mean I think by the time I think it will I reckon a number of those Lorry's would get that waste off. Does it call for something and the only comparable act I can perhaps think of is that things like permitting used to be very disparate and amongst the regions in a different way and we've now got the national permitting service. I'm not saying it's it's perfect but you've got a dedicated team. Now I don't know and tell me if I'm wrong on this. Is there a single number dedicated number that somebody could call to go? Here's the waste crime. They're like crime stoppers I guess and actually it goes through to somebody. They are dedicated. They know who they need to call to make something happen and it means that the public or others don't have to worry. They just call one number and the person at the end of that line would know exactly who they've got to speak to. The channels etc to get it moving to stop all this passing around going. Not my problem not my problem and perhaps a bit more of a behind the scenes coordinated way with something in the front. I just need to get a react fast. I mean and shut the site down and stop people getting access to it. I mean I can't I can't believe that some of the numbers I mean if you work it out if there's a hundred thousand tons in an Arctic Lorry it takes 30 tonne. You work out a hundred thousand to 30 tons. A lot of Lorry's. A lot of Lorry's yeah you know and to not be able to go to a site that no doubt someone sings something that's happening and be able to put security in place or put a sign in place to stop anyone else getting access to that site and just letting it happen and happen happen happen for weeks or months or whatever that's such a high cost to that material. As you say you know with the orders they've got to be heard within a very short period of time it doesn't take a lot to then you know put some concrete barriers or blocks in the way to to stop and they do it quick enough when other things have happened so why not just go and put some concrete blocks in the way to to stop them then getting into that site. So that is what they're from yeah exactly what I've done at Wicked now and Sky News reports on this earlier in the year and a reporter standing in front of you could see the barricades and the blocks and this site where they were told well we can't close it down we can't do that because it's an ongoing criminal investigation which they have done now. So yeah and absolutely and it's very effective and nobody else can can get in there it's effective that's what that's what that bit of the law is there for exactly that reason. From the local authority perspective Gareth how do you see some of this being a bit more more proactive to stop these actions impacting on your local communities it's obviously a lot different in scale but it has just as a visible and sort of social impact because because of where it is. Would I be willing to live near one of these sites? I couldn't I couldn't imagine live in there you know 20,000 or 50,000 or 100,000 tons of waste. Without some real action I'm I'm not sure how you deal with these the major criminals who are doing this because like I said before the low the low-level chances that they're doing this they tend to do it for a while and then yeah move on or you know people start finding some material. I mean it is quite a run out for me as soon as you see a post on Facebook now it sounds as I've got some waste to be cleared you know the amount of responses you see from five six seven eight nine ten people yeah and we take a lot of action here we do a lot of work stop commercial material coming in. New powers are good I didn't need to be used and they don't have you four staff behind them yeah the staff need to be trained they need to have enough staff to be able to deal with it they can't be in Scotland, Ireland, Wales and England at the same time you know it's a big it's a big place so then they almost need like opera task force who can go and shut the site down and get to that site and not and treat it like an emergency you know a situation started we now need to get there we now need to stop something happening and we're not leaving here until we've done all the sort of stuff we can do to stop it happening and you know we've arrested the people we've done our investigations but like Hannah said you know acting four five six months afterwards you know resting people there standing over and it is and the biggest issue for us is you know we have they tip it they tip it without any due care retention that I didn't care just do it for the money we clear it away according to the law and that's why it costs an absolute fortune because we have to treat it we have to we have to do it all properly and by the book so because we have to do that there's a massive cost to it let's say how do you stop a man with a van and they just put an advert out or just you know response stuff it's it's very very difficult say they'll just turn up and take it and you know I wouldn't I personally wouldn't expect I'm in the sector so I might ask some questions all going what we're going to do for 30 quid that's a bit low you know whereas a lot of people won't and especially with a cost of living crisis and all the cost going up they're going to go I can save myself a few quid here without realising perhaps the consequences or implications of it by giving it to some registered you know commercial operation how does actually to me when I've told the story before to then stop me if you've heard it at my mom's house when a man in a van turned up and asked for any scrap metal and I opened the door to him my mom was having a cup of tea and that's said okay can I see waste carriers license please and he looked to me blankly and he said oh go for his driving license that's it all thanks for that which wasn't a UK driving license and I said no waste carriers license you're carrying waste you need a waste carriers license can I see it please before we give you any waste had no idea what I was talking about and run off and then I saw him he clearly already been on the road and on the suspecting house I was like my mom probably would have gone oh I'll give you my crave what we know whatever I don't need so I reported its the environmental agency and I sent a video and I followed it up six months later and I asked him what they've done and the answer was nothing we're in the sector we know this but and you're asking those questions and that then makes it very frustrating for anybody to go well what's the point of me doing something when there's no action then undertaken by the relevant authority nothing gets done and people they just see people getting away with it and and it's just like why do I bother yeah and it's also how civic responsibility civic pride and I want us to do the right thing but others just go out what's the point that that's gives off completely wrong sort of you know sort of picture really that shouldn't be how it is and they should be jumping on these things because you stop the small things it stops the big things exactly yeah yeah and as Garret said earlier he probably would have charged in 30 30 quid to my mom or something if you go all at the road gets searched and then he's probably got the channel this guy news investigation last year is one man with a van but there's actually six or seven of them in a Romanian group apparently yeah they're all doing it and then they all end up in a big field I think it was in heart for sure so it's only one householder who doesn't you know householders don't know the rules like we do not in the industry they're not so it turns them to be a massive enterprise or there's no there's no national you know there's been I did I did something when I worked at our industry cancel pretty 15 years ago now we did quite a lot of work on waste carriers licensees there must be a big push at the time so I'm sorry lots of leaflets and stuff going out but I was us as the local forage doing it not not the EA was if I'm actually was supposed to be the enforcement people there all businesses you know who are advertising about this you think how much material being Q cell which is all it's all commercial it's all being used for yes okay you'd argue and go it's a lot of us at DIYs and stuff like that yeah actually they've got trade point they've got a massive you know trade customer base they should be doing this they need to be doing some of that work with them but I think at the moment I mean I've had it before where some of the stuff we found flytip for example has been canisters that contain like foam so instead of buying like a small can they buy a big big chunk of it to do it in bulk I think those canisters cost 400 pound each to get rid of them we've been quote 700 pound it just doesn't match up yes and it's now empty yeah so you know for materials I know it's only one material stream but you know what from material stream like that yeah then they buy them they paid big deposit on that canister which covers the cost of getting it they'll you know get it with absolutely yeah does it just push it that burden to us yeah and it just as Anna said at the start it just comes back down to it to you and me as taxpayers be it paying into a national pot or paying to our local authorities through the council tax council tax we're we're left to pay for that bill you can't just go well actually we're going to charge a load more on the council tax because we've got to deal with these issues what happened then people again be up in arms about it but it's it's I think it's one of those subjects as well as being very emotive which which quite rightly should be you know it leaves potential health hazards for where these sites are for people and is very damaging for the environment be it surface water ground water you know all of those things and it's very very visible these are one of these things that you know is there as a subject that once you know it's there has a big impact it's it's not hidden out of the way it's yet we we just see it's almost like a decline in social standards it's that's that's sort of see you know lack of pride from certain people because I think there's a box to be made and that's yeah I think that's very very sad so if you could have one thing that you think would make a you know a big difference you could have as is there such a thing as a silver bullet I'm not so sure unless it's a werewolf but let's you know if there was one thing you could have what would it be Anna what would I have and what I wouldn't have I'm wishing Lee's on for this is a bit a lot to be seen for more power need more powers need more legislation and as the garrison touched on no we don't. It's in my view. I'm working law every day. We're up to the eyeballs in law for environmental stuff. It's the enforcement and it's the regulation and people actually getting out and doing stuff. So I think for me, it would be that in a long, windy way of saying, enforcement of what we've got by humans getting out earlier enforcement, acting on what we've, the information that they're given from the public, not ignoring it for months, and then being dragged, kicking and screaming into it just because Sky News found out about it. And that's what I would like is, is actually enforcement by humans getting out on the ground doing stuff, reacting to what the information that they've been given and the intelligence they've been given. We don't need any more laws and powers and everything like that. And the regulation, the environment actually has more powers than the police at the moment. Yeah, under the new environment, well, no, it's not the only more is it post-Brexit, the environment act of 2021, which saw the 1995 act. So that's all there for my view. So yes, I would like more enforcement and more action. What's the, what's the, are we some little less conversation, a little more action, please? Go, I think mine's similar. You know, I'd like to see, there is some quick wins here and there are some quick things that could be dealt with. So dealing with road traders and stuff like that, for example, and not passing the buck all the time, then it's them, all them, all them, all them. You know, if they spent a month advertising on Facebook for someone to come and pick some waste up and every person who turned up, they went, can I see your driver's, your licence and all that sort of stuff, that would probably weed out a bunch of sort of rogue commercial chosen. And Mike Hannah said, what you don't know is those investigations might be done to actually, this is a gang here of people doing this in five trucks. And I think we've never seen that, you know, people are, I remember years ago when we used to report stuff to the environment agency around sort of like we've had this person and they, you go, oh, what actually have you taken, are we told them to get a waste carer's licence? It doesn't really help it. It's a, you know, maybe it's going to get, I don't know whether you've seen the, the streaming series Legends with Steve Cougan, where they went undercover for customs for the, for the drug industry. Perhaps we need to go and get some undercover people into the, the waste industry, because if it's organised crime, there's going to be a whole wider thing going on. So as you say, Gary, perhaps, you know, we only think it's one van, but actually it's not. It's five or six times at working under an organised scheme. Exactly. And that's, to me, that's like that's intelligent, that enforcement isn't it? Yeah. And that's using, joined up in partnership and that's using shared data and at the moment they're just, that just isn't there. You know, most, most, most local frauds are probably sat there going, please don't fly to the Bay Area, please don't fly to the Bay Area, please don't fly to the Bay Area. That's, that's probably where they are, because they don't have the resources, they don't have the skill people, they don't have the money, you know, the amount of fly tips that are just being cleaned up as, it's become a normal piece of work for a crew to, you know, we used to have what we used to call a crew, the EPA crew. And their job was literally to drive around the district in, when I was at Aaron, and their job was to fundamentally react to, you know, it's like emergencies, but actually they spend most of their free time picking up fly tips, getting in and moving as quick as possible. And that, that, you know, we've strived around our hot spots because we never had the, we never had the resource to be able to actually deal with this and try and catch anybody. Yeah. And it's sort of a sad indictment, isn't it, of perhaps where we've got to? Although, then I could, one case that I've dealt with and I'm not, I'm frustrating, luscious. So my clients' commercial paperwork had been found in a fly tip, not well a fly tip, it's outside an ex-employees house at the address of which was known. So my client was into, invite him into your under caution to discuss how their ways to ended up in this road. We explained it and said, this is what's happened. The, we know exactly what's happened. The ex disgruntled employees left and he's taking his pot plant in his box of papers out. He's gone home and he's just chuffed it all in the road, taking his pot plant in. So, and we've tracked it all, we've got his phone number, would you like it all? Not interested at all and prosecuted my client for their waste ending up in a, it wasn't their waste either. It was their documents that have been taken by him. He put them in. So it wasn't waste in the stock, but I said to them, well, what are you going to do about, you know who's done it? Why don't you go after him, knock on his door, we've given you his address, you've got his details, he's the one who's put it there. Didn't bother too difficult, I imagine. I don't know. So my client, as a, you know, professional company got representation, we tried to deal with it, we could, it was cheap of him to pay the fine, I'm afraid, that it was to go to the magistrate's court and argue it, and we've had a discussion about the point of principle. If we do argue, this would probably be successful, but the point, the lesson hasn't been learned, the guy who's done it, it's just got away with it. And we're probably going to do it again. And so I found that, I can see while authority would take, take that action, but that kind of stuff isn't really helping the problem when you just go after the easy target, who you know, is going to pay. I don't finish on a negative note, but that's again, that falls and perhaps that's a whole other discussion. It falls into the, into the regulated sector where it's, as you said earlier on, it's very easy for officers to come around to a site that's open and transparent, and it's, and people can go around yet, site next door that sort of got a big dog barking away, they won't want to go in, they've got a fear of their own safety, and I absolutely understand that, but it, it doesn't address the problems. It means that it allows people to go, actually, I don't give a damn about the law, I'm going to do it in my way, and I'm just going to sort of put off people doing it. And again, it's that, we should, it's, yes, it's hard, but we should be addressing those hard problems because that stops it from getting worse in, you know, later on. It's that sort of out when, when you can, rather than allowing the problem to grow. So now I completely understand that. And I think, um, you know, this almost feels like a, I think we said at the FW conference, it was a bit of a therapy session, allowing it to get out there. It feels like a bit of a, a little bit of a follow on from, from that. And, you know, it would be great to have another podcast to sort of in a few months time, perhaps six months the end of the year or something to see, where do we think things are now? Has there been any change? And hopefully we can say yes to have, and there have been, you know, we can see there's been more arrests, the sites have been stopped a lot quicker, and those numbers of, of orders have gone up much more quickly, and there's, you know, it's better, or there's less flight if been going on, on the local authority level as well. So hopefully we can see some, some, you know, positive changes. How sad would it be if we're coming back for therapy session number three? And actually, there's been, there's been no improvement whatsoever, you know, that leaves a very, um, sort of very sad taste, I think, but fingers crossed, we, we will. And so I'd love to have you back for, um, sort of a follow up towards the end of the year, if you'd both be up for that. Hopefully well for a Christmas positive, um, positive message. Sounds to deliver some positive, positive waste message. So, but I'd like to thank you very, very much for joining me this morning and giving up your, your time. I know you're both very much in demand by the, you know, the, the BBC and others out there. So, so thank you very, very much for giving your, you know, your open honest views on what's going on. Thank you. Thank you. Thanks, David.